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Document ID: OPS-SOP-012  |  Version: 1.0  |  Date: March 2026  |  Owner: Operations  |  Status: Draft — Pending Leadership Review

OPS-SOP-012 — Mid-Year Employer Changes & Terminations

How to handle headcount changes, plan design amendments, and full group terminations for employer groups active under the Unity Care Member Plan Master Trust.

Why this exists: Mid-year changes create eligibility gaps, claims processing errors, and compliance exposure if not handled in sequence across ADP, Employee Navigator, Allied, ProAct, and Varipro. This SOP defines the correct order of operations so changes take effect cleanly across all systems.

1. Types of Mid-Year Changes

Change Type What It Affects SLA / Urgency
New employee enrollment Employee Navigator, Allied, ProAct Process within 30 days of eligibility
Dependent add / removal Employee Navigator, Allied, ProAct Process within 30 days of qualifying event
Termination (single employee) ADP → Employee Navigator → Allied → COBRA (Varipro) Same-day or next-day in ADP
Employer headcount increase (>10%) Contribution amount, stop-loss/captive notification Notify SRS within 30 days
Plan design amendment SPD, SBC, Allied, ProAct configuration SMM required; 60-day advance notice to participants
Full group termination All systems + trust sub-account wind-down See Section 4

2. Individual Employee Changes (Enrollments / Terminations / Life Events)

Step 2.1 — Change Initiated in ADP Employer HR processes change in ADP (new hire enrollment, termination, dependent add/remove, address change). ADP is the source of truth. No change is valid until it exists in ADP.
Owner: Employer HR
Step 2.2 — Employee Navigator Sync ADP feeds Employee Navigator automatically. Employer HR confirms the change is reflected in Employee Navigator within 1 business day. If sync fails, manually update Employee Navigator and flag to Operations.
Owner: Employer HR + Operations (escalation)
Verify within 1 business day of ADP change
Step 2.3 — Allied Eligibility Update Employee Navigator feeds Allied eligibility. Confirm change is live in Allied's system before the employee's next coverage date. For terminations: confirm termination effective date matches between ADP, Employee Navigator, and Allied. Timing mismatch = claims processed for ineligible member.
Owner: Operations
Confirm within 2 business days
Step 2.4 — ProAct Pharmacy Eligibility Update Allied shares eligibility feed with ProAct. Confirm pharmacy eligibility updated for new enrollee or terminated member. For terminations: confirm termination date in ProAct matches Allied.
Owner: Operations
Step 2.5 — COBRA Notification (Terminations Only) ADP auto-triggers COBRA notification to Varipro on qualifying termination events. Operations confirms Varipro received the qualifying event notification within 30 days. Do not manually contact Varipro unless ADP trigger fails.
Owner: Employer HR (ADP) + Operations (confirmation)
COBRA election notice must reach terminated employee within 44 days of qualifying event
Termination Timing Risk: A member terminated in ADP but still active in Allied will have claims processed and funded — creating a financial liability. Always verify termination is reflected in Allied before the next Thursday claims pull.

3. Plan Design Amendments

Step 3.1 — Amendment Initiated Operations identifies need for plan design change (benefit modification, cost-sharing adjustment, new plan tier). Documents proposed change in Asana task with rationale and effective date.
Owner: Operations
Step 3.2 — ERISA Legal Review Route proposed amendment to ERISA Legal Counsel (Dickinson Wright) for review. Confirm: amendment is permissible under existing plan documents; IRS/ACA implications reviewed; waiting period requirements still met.
Owner: ERISA Legal Counsel
Allow 5–10 business days for legal review
Step 3.3 — Compliance Sign-Off Compliance reviews amendment for HIPAA, ACA, MHPAEA, and NSA compliance. Documents sign-off. For ACA changes: confirm minimum value and minimum essential coverage standards still met.
Owner: Compliance
Step 3.4 — Summary of Material Modification (SMM) If amendment constitutes a material modification (change in benefits, cost-sharing, or coverage): distribute SMM to all plan participants 60 days before effective date. ERISA Legal prepares SMM language. Employer HR distributes to employees.
Owner: ERISA Legal (drafting) + Employer HR (distribution)
60 days before effective date — mandatory
Step 3.5 — Update Allied & ProAct Configuration Submit updated plan design to Kim James (Allied) and Dolores Hynes (ProAct). Allow 10 business days for system configuration updates before effective date. Test claims processing against new design before go-live.
Owner: Operations
Step 3.6 — Updated SBC Distribution Obtain updated SBC from Allied reflecting plan design change. Distribute to all participants with or before SMM. Do not allow SBC to be out of date relative to the live plan design.
Owner: Allied (production) + Employer HR (distribution)
Step 3.7 — Primary Approver Sign-Off All plan design amendments require Primary Approver (Dr. Greg) sign-off before effective date. Document approval in Asana task.
Owner: Operations Director → Primary Approver

4. Employer Headcount Changes (>10% swing)

Step 4.1 — Notify SRS Captive Management If employer group grows or shrinks by more than 10% of enrolled headcount: notify Melissa Hancock (SRS) within 30 days. SRS updates captive cell reserve calculations. Significant headcount reduction may affect stop-loss adequacy.
Owner: Operations
Within 30 days of the change
Step 4.2 — Adjust Monthly Trust Contribution Recalculate employer's monthly trust contribution based on updated headcount. Document new contribution amount and effective date. Collect updated premium beginning the next billing cycle.
Owner: Operations + Finance

5. Full Group Termination

CRITICAL: Full group termination must be handled in sequence. Terminating in one system before others creates coverage gaps, COBRA failures, and potential ERISA liability. Do not terminate any group without Operations Director and Primary Approver sign-off.
Step 5.1 — Termination Decision & Documentation Operations documents reason for termination, effective date, and headcount affected. Primary Approver (Dr. Greg) must authorize. Minimum 30-day advance notice to employer group preferred; minimum 60-day advance notice to Allied and ProAct required for clean wind-down.
Owner: Operations Director + Primary Approver
Step 5.2 — ERISA Legal Review ERISA Legal Counsel (Dickinson Wright) reviews termination for: run-out period obligations, COBRA triggering requirements, final SPD/notice obligations, any pending claims that must be processed under the existing plan before termination.
Owner: ERISA Legal Counsel
Step 5.3 — Participant Notification Employer HR distributes written termination notice to all plan participants. Include: termination effective date, last date of coverage, COBRA rights information, and transition options. ERISA Legal prepares notice language.
Owner: Employer HR + ERISA Legal
Minimum 30 days before coverage ends
Step 5.4 — COBRA Triggering (Mass Qualifying Event) Notify Varipro of group termination as a mass qualifying event. All active employees and their dependents are entitled to COBRA continuation. Varipro must receive notice at least 30 days before termination date.
Owner: Operations + Varipro
Step 5.5 — Allied Termination Notify Kim James (Allied) of group termination date. Confirm: last date for claims processing, run-out period (if applicable), final claims register delivery for stop-loss filing.
Owner: Operations
60-day advance notice to Allied
Step 5.6 — ProAct Termination Notify Dolores Hynes (ProAct) of termination date. Confirm pharmacy benefit end date. Collect final invoice and process payment.
Owner: Operations
Step 5.7 — Trust Sub-Account Wind-Down SRS coordinates wind-down of employer's sub-trust account. Confirm: all pending claims funded, final Allied escrow reconciled, any reserve balance disposition per trust agreement.
Owner: SRS Captive Management + Operations
Step 5.8 — Captive Cell Dissolution Captive Counsel (Dickinson Wright) coordinates dissolution or dormancy of employer's protected cell under Unity Care Solutions – TN, LLC. Document cell disposition per Tennessee captive regulations.
Owner: Captive Counsel + SRS
Step 5.9 — Final Compliance Filings Ensure final-year compliance filings are completed: Form 5500 (short plan year if applicable), PCORI fee, final RxDC submission, CAA gag clause attestation. ERISA Legal confirms filing obligations.
Owner: ERISA Legal + Operations

6. Change Log (All Material Changes)

Every material mid-year change must be logged. Stored in: [TBD — change log location]

Date Employer Group Change Type Effective Date Approved By Systems Updated
No changes logged yet — log begins at plan go-live
Version History: v1.0 — March 2026 (initial draft). TBD: run-out period length (confirm with Allied and SRS), change log storage location, specific COBRA notice templates (Varipro to provide).
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